ORDER :

SONIA GOKANI, J.

1. Petitioner is before this Court challenging the proceedings initiated by the show cause notice dated 29.03.2022 issued by the State Tax Officer, Ghatak-11 (Ahmedabad), Gujarat, which culminated into the order dated 28.07.2022 passed by the State Tax Officer canceling the registration of the petitioner Firm under the provisions of Central Goods and Services Tax Act (CBDT) with following reliefs:

“6. The petitioner, therefore, most respectfully prays that this Hon’ble Court be pleased:

(a) To issue a writ in the nature of certiorari and or any other appropriate writs, order or direction for calling of records of proceedings initiated pursuant to show-cause notice dated 29.03.2022 and after perusing the same be pleased to quash and set aside show cause notice dated 29.03.2022 and order dated 28.07.2022 passed thereon by State Tax Officer, Ghatak 11, Ahmedabad and be further pleased to direct restoration of registration bearing number 24AAGHH2510E1ZY;

(b) To pass an ex-parte ad interim order staying the operation, execution and implementation of the order dated 28.07.2022 bearing reference no.ZA240722252266N passed by State Tax Officer, Ghatak 11, Ahmedabad, pending the hearing and final disposal of present petition; and

(c) Grant such further and other interim reliefs, as this Hon’ble Court may deem fit and proper in the nature and circumstances of the case.

2. This Court issued notice on 12.10.2022 and the learned Assistant Government Pleader appeared for the State.

3. We have heard Mr. Maulik Nanavati for the petitioner and Ms.Pooja Ashar, learned Assistant Government Pleader for the respondent-State.

4. It is pointed out to this Court that in the case of Aggarwal Dyeing and Printing Works vs. State of Gujarat, [2022] 137 taxmann.com 332 (Gujarat), this Court held and observed as under:

“10. Thus, upon appreciation of the scheme of Act, where specific forms have been prescribed at each stage right from registration, cancellation and revocation of cancellation of registration, the same are to be strictly adhered too. At the same time, it is equally important that the Proper Officer empowered under the said Act adheres to the principles of natural justice.

11. At the outset, we notice that it is settled legal position of law that reasons are heart and soul of the order and non communication of same itself amounts to denial of reasonable opportunity of hearing, resulting in miscarriage of justice. This Court is bound by the said judgments hereinafter referred to. The necessity of giving reason by a body or authority in support of its decision came for consideration before the Supreme Court in several cases. Initially, the Supreme Court recognized a sort of demarcation between administrative orders and quasi-judicial orders but with the passage of time the distinction between the two got blurred and thinned out and virtually reached a vanishing point in the judgment of the supreme Court in A.K. Kraipak v. Union of India [1970] 1 SCR 457. The Hon’ble Supreme Court vide judgments in the cases of Ravi Yashwant Bhoir v. District Collector, Raigad [2012] 4 SCC 407, Sant Lal Gupta v. Modern Cooperative Group Housing Society Ltd. [2010] 13 SCC 336; Kranti Associates (P) Ltd. vs. Masood Ahmed Khan [2010] 9 SCC 496; Abdul Ghaffar vs. State of Bihar [2008] 3 SCC 258, has expanded the horizon of natural justice and reasons have been treated part of the natural justice. It has gone to the extent in holding that reasons are heart and soul of the order. The absence of reasons renders an order indefensible/unsustainable particularly when it is subject to appeal/revision. It is to be noted that in the case of Kranti Associates (P) Ltd. (supra), the Hon’ble Supreme Court after considering various judgments formulated certain principles which are set out below:

“a. In India the judicial trend has always been to record reasons, even in administrative decisions, if such decisions affect anyone prejudicially.

b. A quasi-judicial authori